2026 AIM Act Update

In September 2025, the EPA proposed a new rule that would extend compliance dates for certain refrigeration technologies. This rule is not final. The EPA is actively refining these requirements, with a final ruling expected in the second quarter of 2026. As of December 22nd, 2025, a non-enforcement period is in effect for the Technology Transition Rule, meaning enforcement is paused until the final rule is published in the Federal Register. 

The Technology Transition Rule is part of the AIM Act of 2020, which mandates the phasedown of hydrofluorocarbons (HFCs) due to their high global warming potential (GWP). The original 2023 ruling set timelines for transitioning to low-GWP refrigerants in air conditioning, heat pump systems, and refrigeration. Since the publication, the refrigeration industry highlighted concerns about cost, supply chain readiness, and safety implications.  

Summary of the Non-Enforcement Period and Proposed GWP limits 

These changes are currently proposed and not yet finalized. The EPA has announced a non-enforcement period that applies only to the interim GWP limits. The final rule is expected to be issued in the second quarter of 2026, and all details remain subject to change until then. 

The revised restrictions for Retail refrigeration equipment include: 

• Interim GWP limit of 1,400: 
  • Effective January 1, 2026 for remote condensing units
  • Effective January 1, 2027 for supermarket systems 
• Proposed final GWP limits starting January 1, 2032
  • GWP of 150 for systems with ≥200 lbs refrigerant charge (excluding high-temperature side of cascade) 
  • GWP of 300 for systems with <200 lbs refrigerant charge or high-temperature side of cascade systems

The revised restrictions for Cold Storage Warehouse refrigeration equipment include: 

• Interim GWP limit of 700 
  • Effective January 1, 2026 for new cold storage warehouses 
• Proposed final GWP limits starting January 1, 2032 
  • GWP of 150 for systems with ≥200 lbs refrigerant charge (excluding high-temperature side of cascade systems)
  • GWP of 300 for systems with 200 lbs refrigerant charge or high-temperature side of cascade systems

The revised restrictions proposed for Refrigerated Laboratory Shakers in the Industrial Process Refrigeration subsector is moved from January 1, 2026 to January 1, 2028.

Note: The HFC refrigerant phasedown schedule established by Congress remains in effect and is not changed by this proposed rule. HFC Refrigerant availability will continue to reduce over the next few years affecting supply and pricing 

Zero Zone’s Response

Although Zero Zone can quote Hybrid™ display cases, purchasers would be aware that compliance with regulations is mandatory. The duration of the current non-enforcement period is uncertain, and the proposed ruling remains under review. To help ensure our customers remain compliant with regulations, Zero Zone will notify you of any modifications required for your order.

We are committed to supporting our customers through this evolving regulatory landscape. While the EPA’s proposed rule may eventually adjust certain deadlines and refrigerant allowances, we are allowed to continue sale of our HFC-refrigerant Hybrid™ display cases, remote condensing units, and remote display cases until the rule is finalized and published in the Federal Register. As always, Zero Zone will continue to follow the currently enacted regulations and compliance timelines.

Zero Zone’s “Refrigerants of 2026” blog outlines the industry’s move towards low-GWP refrigerants such as CO2, Ammonia, A2Ls, and Propane. These refrigerants not only meet the new AIM Act requirements but also deliver reliable performance for both retail and industrial refrigeration systems.

• Low-GWP Refrigerants:
  • CO₂ (R-744): A highly available, non-toxic natural refrigerant with a GWP of 1. Widely used in retail and industrial refrigeration due to its efficiency and minimal environmental impact.
  • Ammonia (R-717): A natural refrigerant with zero GWP and excellent thermodynamic properties. Commonly used in large industrial refrigeration systems; requires careful handling due to toxicity.
  • A2L blends (R-455A, R-454C): Mildly flammable synthetic refrigerants with low GWP, designed to balance performance, safety, and regulatory compliance. Suitable for a range of commercial and industrial applications.
  • Propane: A natural refrigerant with a GWP of less than 1 and high energy efficiency. The Zero Zone self-contained Guardian^® Merchandiser uses propane as a refrigerant.